Code of Ethics and Conflicts of Interests Policy

Owner:  Human Resources
Approved: 6/09/2021

Our organization is dedicated to the purposes for which it was founded which are three fold: first, to provide our customers and the public with the finest banking and financial services of which we are capable; second, to conduct our affairs in such a manner as to insure a sound and profitable operation; and third, to contribute by every means at our command, to the continuing growth and well-being of the communities we serve.

We have agreed to be governed by the following operating principles: “We will be fair, sensitive, honest, trusting and trustworthy in all our dealings among ourselves, with customers, with vendors and with the community at large. We will obey all laws, in fact and in spirit, and we will always strive to do the right thing, in every situation, to the best of our abilities. And if we fail, we will do whatever is required to make amends.”

In keeping with the foregoing, we recognize that a bank, as a business built upon public trust and confidence, depends upon a favorable perception of the conduct of its business by customers, federal and state regulators, stockholders, and others in both the business and general community. It is imperative that each one connected with this organization view his/her business and personal actions, intentions, and impressions upon others objectively with this in mind. Each of us must assure that no one observing our actions, intentions, or impressions would have reason to believe that even the slightest irregularity in conduct exists or could be implied.

It is imperative that each individual so conduct himself or herself at work and in his or her private life as to reflect credit on both the institution and its staff members

Our business and customer information and any related files are confidential and cannot be disclosed to unauthorized persons without the permission of the customer or as allowed by law and in accordance with the bank's privacy policy. It is our policy to treat all information regarding our customers and employees in strictest confidence. Failure to maintain the confidentiality of this information will result in corrective action, up to and including immediate dismissal.

Substantial gifts and excessive entertainment from customers -- particularly borrowers or persons or firms selling products or services to the bank or holding company should be courteously and tactfully declined. Gifts or favors of nominal value which are unrelated to a particular banking transaction may be accepted. “Nominal value” means gifts or favors with a value of less than $100.

Interest rates on deposits and loans, terms of loans and transaction charges, etc., must be determined solely on the basis of what is in the best interests of the bank and its customers.

While stock ownership is encouraged, active trading is not. Trades should never be made on inside information. Particular restrictions apply to Directors, Executive Officers, and other insiders as set forth in Community Bancorp.’s Insider Trading Compliance Policy.

Competition with other financial institutions should always be positive, not negative. 

Although we have a policy of maintaining good relations with all news media and try to accommodate media inquiries, there is much information concerning the company that should not be made available to the public. Any media inquiry made about the bank or a customer should be referred to our Marketing Director, Tracy Roberts, or one of the Executive Officers. The President and CEO shall be the principal spokesperson for the bank.

Members of the staff must avoid dealing for the bank with any person or firm with whom they, as individuals, have any connection or financial interest. Directors will avoid involvement of any kind in the credit approval process when the credit being considered will directly or indirectly benefit him or her. Staff members may not transact personal business with the bank by “waiting on yourself.” All such transactions should be handled by a disinterested associate.

While describing all the circumstances and conditions and possible conflicts of interest which might develop is impossible, the following is set forth for the guidance of all employees:

  1. Full time employees have an obligation to devote their time at work to employment with the Bank and may not engage in any outside employment without disclosure to the Executive Officers through the Director of Human Resources.
  2. If an employee, spouse or other member of any employee's immediate family is engaged in a business similar in nature to the Bank's, it must be disclosed to the Executive Officers through the Director of Human Resources.
  3. No employee may engage in outside work that might interfere with his or her primary job with the Bank nor shall any employee engage in any activity of a nature that is in some way hostile or adverse to the Bank.
  4. No outside work may be done during regular office hours except to the extent that such work is required by your job description or with respect to which permission has been received.

Any questions regarding a possible conflict of interest or outside work should be brought to the attention of the Director of Human Resources.

While it is expected that Directors, Advisory Council Members, officers and employees of the bank will also be loan, deposit and/or trust customers, their business with the bank shall be conducted on the same terms and conditions as other customers, except for those special benefits provided our employees, including a free checking account and special employee loan rates. Special loan rates do not apply to Directors, Advisory Council Members or Executive Officers.

Bank property held in OREO, repossessed property or intangibles (like promissory notes or other negotiable instruments) shall not be sold or otherwise transferred to Directors, Advisory Council Members, or officers or their related organizations. OREO or repossessed property may be sold to employees but only on the same terms as offered to others and only through a broker or by sealed bid. Bank owned tangible personal property, like used furniture and equipment, (but not items repossessed from customers) may be sold to Directors, Advisory Council Members, officers or employees in the discretion of senior management.

Directors, Advisory Council Members, officers, and employees have been and are encouraged to be active and involved participants in the community in a variety of ways, primarily through involvement in civic, charitable or non-profit community activities. Employees are encouraged to actively participate in non-profit organizations such as educational, religious, health and welfare institutions and service clubs. They are also encouraged to serve their communities and schools by service on committees and boards, and involvement in civic activities. To the extent that such activities may occur on bank time, employees must get approval from their supervisor and the Director of Human Services.

The bank will not withhold or deny, on any prohibited basis, any accommodations, advantages, facilities, and privileges of the bank from any person.

It is against the policy of the bank, and illegal under state and federal law, for any employee to sexually harass another employee. The bank is committed to providing a workplace free from this unlawful conduct. For further guidance in this area, reference may be made to the bank's Sexual Harassment Policy.

Similarly, the bank’s policy prohibits violent or threatening behavior, verbal or physical, toward any bank employee or customer that may result in physical or emotional injury or place one’s safety or productivity at risk.  

Violations of this policy should be reported to the Director of Human Resources. The bank will not discriminate against any complainant hereunder, unless a complaint is determined to have been filed in bad faith or to harass employees of the bank. Violations of the principles set forth in this policy may result in reprimands or dismissal with the first offense.